Exemption needed for ag machinery in Ecodesign lighting legislation

FEM, CECE, CEMA and EGMF are the European federations representing manufacturers of materials handling, construction, agricultural and garden machinery. We would like to provide our views on the draft Ecodesign Regulation on light sources and separate control gears to achieve a balanced regulatory framework.

Several types of CECE, CEMA, FEM and EGMF equipment will be impacted by an Ecodesign Regulation on light sources and separate control gears, the draft of which was presented to the Ecodesign Consultation Forum in December 2017.

Indeed, lighting products covered by the draft Regulation are integrated into materials handling equipment (e.g. industrial trucks, telehandlers and mobile elevating work platforms), agricultural machinery (e.g. agricultural tractors and combine harvesters), construction equipment (e.g. excavators and bulldozers) and garden equipment (e.g. lawnmowers).

Lighting products are typically installed in equipment for road circulation purposes and they are also essential to ensure safety of workers in factory plants, construction sites and fields.

According to the current draft Regulation, lighting products would be out of the scope of the regulation only if they are installed in motor vehicles (as defined in Annex I point 1 (d)). We believe that our equipment should benefit from the same possibility, and this for several reasons:

  • Our equipment is fitted with the same lighting products for on-road use as motor vehicles (e.g. tail, brake and headlights and direction indicators). A differentiation between equipment with and without public road application would thus lead to unfair competition, unnecessary additional effort for OEMs and confusion on the market.
  • Our equipment presents a large variety of types reflecting the diversity of its purposes. Yet, it represents altogether small volumes compared to the automotive sector. Consequently, the current draft Ecodesign requirements are likely to affect the supply of appropriate lighting equipment for our equipment. Suppliers will not provide the same product range for the small volume non-road mobile machinery and tractors as they will do for cars and trucks.
  • Contrarily to better regulation principles, there has been no assessment related to our equipment of the proposal’s impact on the environment, consumers, manufacturers, innovation, costs and benefits.

Therefore, FEM, CECE, CEMA and EGMF believe that the abovementioned exclusion should be extended to lighting products for non-road mobile machinery (NRMM) as defined in the Regulation (EU) 2016/1628, and to agricultural tractors, trailers and towed equipment as defined in Regulation (EU) 167/2013.